On June 21, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Llerena, Roberto,
Llerena, Xiomara,
and
Andres Quintana Inc,
Learning And Growing Family Child Care,
Quintana Family Day Care Home,
for Comm Premises Liability
in the District Court of Miami-Dade County.
Preview
Filing # 63081371 E-Filed 10/19/2017 04:56:55 PM
USL-24 1 48M/CP 79 /D)S:hinc.
IN THE CIRCUIT COURT OF THE
TITH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.: 17-014926 CA 01 (31)
XIOMARA LLERENA AND
ROBERTO LLERENA ,
Plaintiffs,
Vv.
QUINTANA FAMILY DAY CARE HOME
D/B/A LEARNING AND GROWING FAMILY
CHILD CARE,
Defendants.
é
DEFENDANT’S MOTION FOR EXTENSION OF TIME
FO RESPOND TO PLAINTIFF'S DISCOVERY REQUESTS
Defendant, QUINTANA FAMILY DAY CARE HOME D/B/A LEARNING AND
GROWING FAMILY CHILD CARE, by and through the undersigned counsel, and pursuant
to the Florida Rules of Civil Procedure, file this Motion for Extension of Time to Respond to
Plaintiffs Requests Propounded with the Complaint, and in support states:
1. Plaintiffs propounded their First Set of interrogatories and First Request for
Production on Defendant on or about July 14, 2017 with the Summons and
Complaint.
2. Plaintiffs Complaint was subsequently amended by interlineaton on August 8, 2017,Case No.: 17-014926 CA 01 (31)
Page 2
3. Defendant respectfully requests an additional thirty (30) days within which to
reasonably obtain the necessary information and documents to respond to Plaintiffs’
discovery.
4. Discovery in the case is in its infancy and Plaintiff will not be prejudiced if this
motion is granted.
5. This motion is made in good faith and not for the purpose of delay.
6. Defendant's case would be severely prejudiced if this extension were not granted.
WHEREFORE, the Defendant, QUINTANA FAMILY DAY CARE HOME D/B/A
LEARNING AND GROWING FAMILY CHILD CARE, by and through the undersigned
counsel, hereby requests that this Honorable Court enter an Order granting a thirty (30) day
extension of time on which to file Defendant’s Responses to Plaintiffs First Set of
interrogatories and First Request for Production and such further relief that this Court
deems fair and proper.Case No.: 17-014926 CA 01 (31)
Page 2
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via Electronic Mail, to all counsel of record on the attached Service List, this 19
day of October 2017.
LUKS, SANTANIELLO,
PETRILLO & JONES
Attorneys for Defendant
150 W. Flagler Street, Suite 2750
Miami, FL 33130
Telephone: (305) 377-8900
Facsimile: (305) 377-8901
By:___/s/ Heather alhoon _
DANIEL |. SANTANIELLO
Florida Bar No.: 860948
HEATHER M. CALHOON
Florida Bar No.: 495573
LUKSMIA-Pleadings@LS-Law.comCase No.: 17-G14926 CA 01 (31)
Page 4
Michael }, Carmona, Esq.
Friedland Law Group
1430 South Dixie Highway
Suite 305
Coral Gables, FL 33146
email@friedlandlawgroup.com
Document Filed Date
October 19, 2017
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
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Filing # 63081371 E-Filed 10/19/2017 04:56:55 PM USL-24 1 48M/CP 79 /D)S:hinc. IN THE CIRCUIT COURT OF THE TITH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 17-014926 CA 01 (31) XIOMARA LLERENA AND ROBERTO LLERENA , Plaintiffs, Vv. QUINTANA FAMILY DAY CARE HOME D/B/A LEARNING AND GROWING FAMILY CHILD CARE, Defendants. é DEFENDANT’S MOTION FOR EXTENSION OF TIME FO RESPOND TO PLAINTIFF'S DISCOVERY REQUESTS Defendant, QUINTANA FAMILY DAY CARE HOME D/B/A LEARNING AND GROWING FAMILY CHILD CARE, by and through the undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, file this Motion for Extension of Time to Respond to Plaintiffs Requests Propounded with the Complaint, and in support states: 1. Plaintiffs propounded their First Set of interrogatories and First Request for Production on Defendant on or about July 14, 2017 with the Summons and Complaint. 2. Plaintiffs Complaint was subsequently amended by interlineaton on August 8, 2017,Case No.: 17-014926 CA 01 (31) Page 2 3. Defendant respectfully requests an additional thirty (30) days within which to reasonably obtain the necessary information and documents to respond to Plaintiffs’ discovery. 4. Discovery in the case is in its infancy and Plaintiff will not be prejudiced if this motion is granted. 5. This motion is made in good faith and not for the purpose of delay. 6. Defendant's case would be severely prejudiced if this extension were not granted. WHEREFORE, the Defendant, QUINTANA FAMILY DAY CARE HOME D/B/A LEARNING AND GROWING FAMILY CHILD CARE, by and through the undersigned counsel, hereby requests that this Honorable Court enter an Order granting a thirty (30) day extension of time on which to file Defendant’s Responses to Plaintiffs First Set of interrogatories and First Request for Production and such further relief that this Court deems fair and proper.Case No.: 17-014926 CA 01 (31) Page 2 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Electronic Mail, to all counsel of record on the attached Service List, this 19 day of October 2017. LUKS, SANTANIELLO, PETRILLO & JONES Attorneys for Defendant 150 W. Flagler Street, Suite 2750 Miami, FL 33130 Telephone: (305) 377-8900 Facsimile: (305) 377-8901 By:___/s/ Heather alhoon _ DANIEL |. SANTANIELLO Florida Bar No.: 860948 HEATHER M. CALHOON Florida Bar No.: 495573 LUKSMIA-Pleadings@LS-Law.comCase No.: 17-G14926 CA 01 (31) Page 4 Michael }, Carmona, Esq. Friedland Law Group 1430 South Dixie Highway Suite 305 Coral Gables, FL 33146 email@friedlandlawgroup.com